Continental Investors Services, Inc.

Allegations: VIOLATION OF MSRB RULE G-17,G-30(A)AND G-27.FIRM SOLD MUNICIPAL SECURITIES FOR ITS OWN ACCOUNT TO A CUSTOMER AT AN AGGREGATE PRICE (INCLUDING ANY MARKDOWN OR MARKUP) THAT WAS NOT FAIR AND REASONABLE. TAKING INTO CONSIDERATION ALL RELEVANT FACTORS, INCLUDING THE BEST JUDGMENT OF THE FIRM AS TO THE FAIR MARKET VALUE OF THE SECURITIES AT THE TIME OF THE TRANSACTION AND OF ANY SECURITIES EXCHANGED OR TRADED IN CONNECTION WITH THE TRANSACTION, THE EXPENSE INVOLVED IN EFFECTING THE TRANSACTION, THE FACT THAT THE FIRM IS ENTITLED TO A PROFIT AND THE TOTAL DOLLAR AMOUNT OF THE TRANSACTION. THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLE DESIGNED TO ACHIEVE COMPLIANCE WITH APPLICABLE SECURITES LAWS, REGULATIONS AND MSRB RULES CONCERNING FAIR PRICING FOR MUNCIPAL SECURITIES TRANSACTIONS. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS; THEREFORE, THE FIRM IS CENSURED, FINED $35,000 AND REQUIRED TO REVISE ITS WRITTEN SUPERVISORY PROCEDURES REGARDING FAIR PRICING FOR MUNICIPAL SECURITIES TRANSACTIONS WITHIN 30 BUSINESS DAYS OF ACCEPTANCE OF THIS AWC BY THE NAC FOR VIOLATION OF MSRB RULES G-17,G-27 AND G-30(A). Summary: RESTITUTION AND INTEREST WAS PAID ON 4-21-2011 TO NINE CUSTOMERS WHO WERE INCORRECTLY CHARGED. FINE OF $35,000 WAS PAID ON 8-23-2011.

Allegations: CIS WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS FAILED TO REPORT TRACE ELIGIBLE SECURITIES WITHIN 75 MINUTES AFTER EXECUTION. Status: Final Sanction Detail: FINE IN THE AMOUNT OF $5,000 TO BE PAID BY CREDIT CARD FOR THE FULL AMOUNT. Summary: FIRM DID REPORT TRACE ELIGIBLE SECURITIES TRADES, HOWEVER, DURING THE PERIOD OF AUGUST 1, 2002 THROUGH SEPTEMBER 30, 2002 734 TRANSACTIONS WERE REPORTED AFTER THE 75 MINUTE REPORTING REQUIREMENT.

Allegations: THE FIRM EXECUTING A TRADE IN THE ACCOUNT OF NEW MEXICO RESIDENT, DAVID LUND, PRIOR TO BEING LICENSE IN NEW MEXICO. Status: Final Sanction Detail: THE FIRM PAID A $500.00 CIVIL PENALTY ON 10/03/2000. NONE OF THE PENALTY WAS WAIVED. THE FIRM SIGNED A "UNDERTAKING" WITH THE STATE OF NEW MEXICO AND COMPLETED A RESCISSION OFFER FOR DAVID LUND. Summary: UNDERTAKING SIGNED AND APPROVED ON 10-17-2000. CHECK NO. 9744 IN THE AMOUNT OF $500.00 DATED 10-03-2000. PROOF OF RESCISSION OFFER, DATED 10-3-2000.